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Understanding the Role of Compostable Packaging in North America

Understanding the Role of Compostable Packaging in North

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Page 1: Understanding the Role of Compostable Packaging in North

Understanding the Role of Compostable Packaging in North America

About usGreenBlue is an environmental nonprofit dedicated to the sustainable use of materials in society We bring together a diversity of stakeholders to encourage innovation and best practices to promote the creation of a more sustainable materials economy

The Sustainable Packaging Coalition is a membership-based collaborative that believes in the power of industry to make packaging more sustainable We are the leading voice on sustainable packaging and we are passionate about the creation of packaging that is good for people + the environment Our mission is to bring packaging sustainability stakeholders together to catalyze actionable improvements to packaging systems and lend an authoritative voice on issues related to packaging sustainability The Sustainable Packaging Coalition is a trademark project of GreenBlue Org

AuthorsLead AuthorOlga Kachook Senior Manager Sustainable Packaging Coalition

EditorsKelly Cramer Lead of How2Recycle amp Director Program ManagementAdam Gendell Associate Director Sustainable Packaging Coalition

CitationUse of the contents of this guide is permitted provided the source is cited Suggested citation Sustainable Packaging Coalition (2021 January) Understanding the Role of Compostable Packaging in North America [PDF] Retrieved from httpssustainablepackagingorgresources

AcknowledgementsThe team would like to thank the following stakeholders from the compostable packaging composting advocacy and certification spaces who reviewed this document

Buzz Chandler Asean Corporation Frank Franciosi US Composting Council Janet Thoman Compost Manufacturing Alliance LLCJessica Bowman Plant Based Products CouncilRenaud des Rosiers Amyrsquos KitchenRhodes Yepsen Biodegradable Products Institute Shannon Pinc NatureWorksSusan Thoman Compost Manufacturing Alliance LLCWendell Simonson Biodegradable Products Institute

Introduction Why Are We Exploring Compostable Packaging Value of Compostable Packaging Basics of Compostable Packaging

Collection Insights Into Composting Infrastructure and AccessAvailability of Composting Infrastructure Residential Access to Composting Programs Legislation that Supports InfrastructureKey Takeaways for Composting Collection

Composters Understanding Technologies and Challenges Types of Composting Technologies End Markets for Finished CompostAddressing Contamination

Consumer Education Communicating Compostability to Consumers Consumer Perceptions of Compostability Education Through Certifications and LabelingEngaging Consumers on Composting

Design Starting with the Right ApplicationsBest-use Applications for Compostable Packaging Checklist for Compostability Gray Areas for Compostable Packaging What Shouldnrsquot Be Compostable

The Future of Compostable Packaging Future DesignFuture Collection Future CompostingFuture Consumer Education

Con

ten

ts248

12141920

222325

303134

36394042

46474849

1

11

21

29

35

44

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 2: Understanding the Role of Compostable Packaging in North

About usGreenBlue is an environmental nonprofit dedicated to the sustainable use of materials in society We bring together a diversity of stakeholders to encourage innovation and best practices to promote the creation of a more sustainable materials economy

The Sustainable Packaging Coalition is a membership-based collaborative that believes in the power of industry to make packaging more sustainable We are the leading voice on sustainable packaging and we are passionate about the creation of packaging that is good for people + the environment Our mission is to bring packaging sustainability stakeholders together to catalyze actionable improvements to packaging systems and lend an authoritative voice on issues related to packaging sustainability The Sustainable Packaging Coalition is a trademark project of GreenBlue Org

AuthorsLead AuthorOlga Kachook Senior Manager Sustainable Packaging Coalition

EditorsKelly Cramer Lead of How2Recycle amp Director Program ManagementAdam Gendell Associate Director Sustainable Packaging Coalition

CitationUse of the contents of this guide is permitted provided the source is cited Suggested citation Sustainable Packaging Coalition (2021 January) Understanding the Role of Compostable Packaging in North America [PDF] Retrieved from httpssustainablepackagingorgresources

AcknowledgementsThe team would like to thank the following stakeholders from the compostable packaging composting advocacy and certification spaces who reviewed this document

Buzz Chandler Asean Corporation Frank Franciosi US Composting Council Janet Thoman Compost Manufacturing Alliance LLCJessica Bowman Plant Based Products CouncilRenaud des Rosiers Amyrsquos KitchenRhodes Yepsen Biodegradable Products Institute Shannon Pinc NatureWorksSusan Thoman Compost Manufacturing Alliance LLCWendell Simonson Biodegradable Products Institute

Introduction Why Are We Exploring Compostable Packaging Value of Compostable Packaging Basics of Compostable Packaging

Collection Insights Into Composting Infrastructure and AccessAvailability of Composting Infrastructure Residential Access to Composting Programs Legislation that Supports InfrastructureKey Takeaways for Composting Collection

Composters Understanding Technologies and Challenges Types of Composting Technologies End Markets for Finished CompostAddressing Contamination

Consumer Education Communicating Compostability to Consumers Consumer Perceptions of Compostability Education Through Certifications and LabelingEngaging Consumers on Composting

Design Starting with the Right ApplicationsBest-use Applications for Compostable Packaging Checklist for Compostability Gray Areas for Compostable Packaging What Shouldnrsquot Be Compostable

The Future of Compostable Packaging Future DesignFuture Collection Future CompostingFuture Consumer Education

Con

ten

ts248

12141920

222325

303134

36394042

46474849

1

11

21

29

35

44

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 3: Understanding the Role of Compostable Packaging in North

AuthorsLead AuthorOlga Kachook Senior Manager Sustainable Packaging Coalition

EditorsKelly Cramer Lead of How2Recycle amp Director Program ManagementAdam Gendell Associate Director Sustainable Packaging Coalition

CitationUse of the contents of this guide is permitted provided the source is cited Suggested citation Sustainable Packaging Coalition (2021 January) Understanding the Role of Compostable Packaging in North America [PDF] Retrieved from httpssustainablepackagingorgresources

AcknowledgementsThe team would like to thank the following stakeholders from the compostable packaging composting advocacy and certification spaces who reviewed this document

Buzz Chandler Asean Corporation Frank Franciosi US Composting Council Janet Thoman Compost Manufacturing Alliance LLCJessica Bowman Plant Based Products CouncilRenaud des Rosiers Amyrsquos KitchenRhodes Yepsen Biodegradable Products Institute Shannon Pinc NatureWorksSusan Thoman Compost Manufacturing Alliance LLCWendell Simonson Biodegradable Products Institute

Introduction Why Are We Exploring Compostable Packaging Value of Compostable Packaging Basics of Compostable Packaging

Collection Insights Into Composting Infrastructure and AccessAvailability of Composting Infrastructure Residential Access to Composting Programs Legislation that Supports InfrastructureKey Takeaways for Composting Collection

Composters Understanding Technologies and Challenges Types of Composting Technologies End Markets for Finished CompostAddressing Contamination

Consumer Education Communicating Compostability to Consumers Consumer Perceptions of Compostability Education Through Certifications and LabelingEngaging Consumers on Composting

Design Starting with the Right ApplicationsBest-use Applications for Compostable Packaging Checklist for Compostability Gray Areas for Compostable Packaging What Shouldnrsquot Be Compostable

The Future of Compostable Packaging Future DesignFuture Collection Future CompostingFuture Consumer Education

Con

ten

ts248

12141920

222325

303134

36394042

46474849

1

11

21

29

35

44

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 4: Understanding the Role of Compostable Packaging in North

AcknowledgementsThe team would like to thank the following stakeholders from the compostable packaging composting advocacy and certification spaces who reviewed this document

Buzz Chandler Asean Corporation Frank Franciosi US Composting Council Janet Thoman Compost Manufacturing Alliance LLCJessica Bowman Plant Based Products CouncilRenaud des Rosiers Amyrsquos KitchenRhodes Yepsen Biodegradable Products Institute Shannon Pinc NatureWorksSusan Thoman Compost Manufacturing Alliance LLCWendell Simonson Biodegradable Products Institute

Introduction Why Are We Exploring Compostable Packaging Value of Compostable Packaging Basics of Compostable Packaging

Collection Insights Into Composting Infrastructure and AccessAvailability of Composting Infrastructure Residential Access to Composting Programs Legislation that Supports InfrastructureKey Takeaways for Composting Collection

Composters Understanding Technologies and Challenges Types of Composting Technologies End Markets for Finished CompostAddressing Contamination

Consumer Education Communicating Compostability to Consumers Consumer Perceptions of Compostability Education Through Certifications and LabelingEngaging Consumers on Composting

Design Starting with the Right ApplicationsBest-use Applications for Compostable Packaging Checklist for Compostability Gray Areas for Compostable Packaging What Shouldnrsquot Be Compostable

The Future of Compostable Packaging Future DesignFuture Collection Future CompostingFuture Consumer Education

Con

ten

ts248

12141920

222325

303134

36394042

46474849

1

11

21

29

35

44

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 5: Understanding the Role of Compostable Packaging in North

Introduction Why Are We Exploring Compostable Packaging Value of Compostable Packaging Basics of Compostable Packaging

Collection Insights Into Composting Infrastructure and AccessAvailability of Composting Infrastructure Residential Access to Composting Programs Legislation that Supports InfrastructureKey Takeaways for Composting Collection

Composters Understanding Technologies and Challenges Types of Composting Technologies End Markets for Finished CompostAddressing Contamination

Consumer Education Communicating Compostability to Consumers Consumer Perceptions of Compostability Education Through Certifications and LabelingEngaging Consumers on Composting

Design Starting with the Right ApplicationsBest-use Applications for Compostable Packaging Checklist for Compostability Gray Areas for Compostable Packaging What Shouldnrsquot Be Compostable

The Future of Compostable Packaging Future DesignFuture Collection Future CompostingFuture Consumer Education

Con

ten

ts248

12141920

222325

303134

36394042

46474849

1

11

21

29

35

44

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 6: Understanding the Role of Compostable Packaging in North

Compostable packaging is receiving significant attention from brands and retailers Though composting infrastructure is not yet widespread across the US interest in this recovery pathway is growing rapidly As more communities look to divert food scraps (currently at least 21 of the waste stream) out of the landfill composting (also referred to as organic recycling) will be a big part of their materials management strategy At the same time cities across the US are beginning to require compostable packaging for foodservice vendors and retailers quick service chains and even airlines are jumping on board

Itrsquos not just foodservice thatrsquos turning to compostable packaging In response to recycling challenges CPGs are also starting to include compostable packaging as part of their packaging sustainability goals Unilever Aldi and PepsiCo have all included compostable packaging as part of their strategy for tackling currently unrecoverable packaging waste Consumers are increasingly interested in compostable packaging options but also confused about their value and how to dispose of them

This guide aims to provide a framework for understanding the best role for compostable packaging in a sustainable packaging strategy It offers considerations for appropriate use cases insights into composting infrastructure and municipal collection programs and perspectives on composter and consumer engagement It clarifies the recovery ecosystem surrounding compostable packaging today for the benefit of brands retailers municipalities consumers and other stakeholders

While this guide focuses on composting as a recovery pathway for packaging recovery is only one aspect of sustainable packaging - there are also important sourcing manufacturing and material health considerations These will impact the overall environmental footprint of the packaging and should be examined closely

Collection

CompostingDesign

Consumer Engagement

Introduction

1

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 7: Understanding the Role of Compostable Packaging in North

Compostable packaging is part of global commitments for better packaging

The Ellen MacArthur Foundationrsquos New Plastics Economy includes compostable packaging as one pathway to building circularity for plastics that are not eliminated More than 450 companies have signed on to the New Plastics Economy commitment to date While not all of these companies will pursue compostable packaging many are interested in substituting some of their packaging portfolios with compostable alternatives W hat products a re most appropriate for compostable packaging applications This question is explored in the Design section of this guide

Compostable packaging can be an alternative to currently non-recoverable plastic waste

For packaging that is not readily recyclable compostable packaging may provide an alternative recovery pathway A recent SYSTEMIQ analysis identified the need for substitutes to non-recoverable plastic to help manage plastic waste These substitutes include compostable bioplastics coated paper (which may be recyclable compostable or neither depending on the coating) and paper (which may be compostable if wet or food-soiled and free of harmful additives) Substitutions like these may be a viable option for packaging that cannot be eliminated reused or recycled However to effectively manage litter and plastic waste merely reconsidering the material selected for the package is insufficient We need to critically analyze the packagersquos broader relationship to systems of consumer use and recovery in mind which means investing in composting infrastructure or assessing whether the material can be eliminated altogether What is the state of North American composting infrastructure and where can these products be composted These questions are explored in the Collection and Composters sections of this guide

Figure 1 New Plastics Economy Vision statement which includes compostable materials

Why Are We Exploring Compostable Packaging

2

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 8: Understanding the Role of Compostable Packaging in North

The purpose and value of compostable packaging is widely misunderstood

Consumers brands retailers and packaging manufacturers are confused about where compostable packaging fits into a companyrsquos sustainability efforts At the same time there are ongoing widespread public misconceptions around both the benefits and drawbacks of compostable packaging Some media coverage portrays compostable packaging as a welcome innovation for every application and the predominant solution to marine plastic pollution which is incorrect In other instances compostable packaging is described as not truly compostable which is also incorrect Brands working with compostable packaging must strive to understand the intersection of systems of food waste composting infrastructure and marine pollution How does compostable packaging affect a composting facility What do consumers think about compostable packaging These questions are explored in the Composters and Consumers sections of this guide

Figure 2 Pew Charitable Trust SYSTEMIQ 2020 Compostables can substitute commonly-leaked plastic items that contribute to mismanaged plastic waste

3

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 9: Understanding the Role of Compostable Packaging in North

What is the value of compostable packaging and why do we need it as part of a suite of solutions that improve the sustainability of packaging

Value of Compostable Packaging

4

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 10: Understanding the Role of Compostable Packaging in North

Capturing and diverting food waste

Compostable packagingrsquos primary value is when it is used to capture food waste and deliver it to the composting bin Food waste in landfills is a large source of methane a greenhouse gas which is 25 times more potent than carbon dioxide at warming our planet More food waste is diverted in packaging and food waste programs than in food-only composting programs

Compostable packaging can be used in foodservice settings where itrsquos likely that the plate cup clamshell or tray will have food residue or food scraps Once a consumer is finished eating or storing the contents both the packaging and the remaining leftovers can be composted together

Compostable packaging acts as a vehicle for divertingfood waste More food waste is diverted in packaging and food waste programs than in food-only composting programs

Learn more here Value of Compostable Packaging

Simplified consumer experience and a cleaner recycling stream

When a suite of compostable packaging is used consumers donrsquot need to sort wash or separate food scraps from packaging Their takeout container and utensils can be placed directly in the composting bin along with any leftovers This helps simplify the process of composting both at home and on the go lowering the barriers for consumers to compost food waste

This is particularly true for packaging used in closed venues such as stadiums airports university and corporate campuses If compostable packaging is used exclusively in these environments consumers receive a simplified message about how to sort their waste

A compostables-only approach to food serviceware and heavily food-soiled packaging can also lead to cleaner recyclables If this packaging is consistently labeled and collected for composting less food waste and mis-identified compostable packaging will be put into the recycling bin

Learn more here A case study for composting Taco Time Northwest 5

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 11: Understanding the Role of Compostable Packaging in North

A solution for non-recyclable packaging

Compostability can be a recovery pathway for packaging that is in contact with food and is not recyclable today This includes packaging such as meat trays cheese wrappers produce trays and cling film used in a variety of grocery and packaged food applications

In these applications it is difficult to recover the packaging for recycling often because it is made of lightweight flexible plastic packaging Store drop-off is one way of recycling film but is limited to clean and dry flexible plastic made from PE such as plastic bags and plastic wrap

While compostable solutions to non-recyclable flexible packaging are still nascent if properly designed and labeled they may be a promising option to help companies meet their packaging goals

Learn more here Compostable Overwrap for Tea Bags

Supporting biological cycles of the circular economy

The circular economy consists of both technical and biological loops of materials Recycling supports the recovery of technical nutrients such as metals and polymers

Meanwhile in biological cycles food and biologically-based materials (such as cotton or wood) can feed back into the system through processes like composting and anaerobic digestion

Compostable packaging can be designed as a biological nutrient that once used will decompose in a composting environment without negatively affecting soil quality

Learn more here What is a Circular Economy

6

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 12: Understanding the Role of Compostable Packaging in North

Compost supports soils as a carbon sink

Carbon sinks are environments that absorb and store more carbon than they release lowering the concentration of carbon dioxide in the atmosphere Globally the two most important carbon sinks are vegetation and the ocean

Land sinks such as forests help to return 26 of human-caused emissions into the earth Soil is an enormous storehouse of carbon and soil with more carbon content is also more agriculturally-productive and resilient

Experiments by the Marin Carbon Project have shown that applying compost can double soil carbon sequestration Vast quantities of compost can be applied to soil everywhere sequestering carbon and reducing demand for nitrogen fertilizers Compost should be recognized as a key tool for absorbing carbon

Learn more here Compost Key to Sequestering Carbon in the Soil

Supplementing carbon sources in the composting process

Because compostable packaging is used to divert food waste it is often assumed that there is no inherent value to the composting process from the packaging itself

In fact fiber-based compostable packaging can serve as a valuable source of carbon in the composting process A composting operation needs sources of fiber such as wood chips to mix with other organic material During the winter composters may have trouble getting natural sources of carbon like yard waste which is generated and captured predominantly in warmer seasons

In a composting operation compostable packaging can serve as a bulking agent adding structure or bulk to the compost pile in the same way as carbon-based yard waste materials

Learn more here Value Of Compostable Packaging As ldquoFeedstockrdquo

7

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 13: Understanding the Role of Compostable Packaging in North

Fiber packaging is typically made out of tree fiber or plant fiber such as sugarcane wheatstraw or bamboo Fiber is often used to make paper plates takeout containers boxes sleeves (such as for bakery items) or pouches Fiber packaging that requires grease or moisture resistance is often lined with a bioplastic

Compostable bioplastic packaging can be made out of a wide variety of bioplastics The most common examples of bioplastics used are PLA cellulose starch blends PBS and PHA Many of these bioplastics are also bio-based while others like PBAT are only partially biobased today and may still include fossil-based materials

Compostable packaging is a specific type of biodegradable packaging Compostable materials are degradable by biological processes to yield carbon dioxide water inorganic compounds and biomass at a rate consistent with biodegradation of natural waste while leaving no visually distinguishable remnants or unacceptable levels of toxic residues ldquoBiodegradablerdquo is a more general concept that refers to materials breaking down over unspecified amounts of time and usually in unspecified environments In this guide we use the term ldquocompostablerdquo to describe packaging designed for composting as an end-of-life solution

Compostable packaging can be broken down into two material categories fiber packaging and compostable bioplastic packaging

There are important life cycle considerations surrounding compostable packaging While they tend to have higher water use and aquatic toxicity impacts they also tend to have lower greenhouse gas emissions and fossil fuel use Life cycle assessments (LCAs) can be used to better understand the impacts from the sourcing and manufacture of these materials At the same time we should keep in mind that LCAs are not perfect tools and the robustness of their findings can be limited by the boundaries set availability and recency of data and other factors

Biodegradable

Compostable

Basics of Compostable Packaging

8

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 14: Understanding the Role of Compostable Packaging in North

Packaging can be designed to be commercially compostable (also referred to as industrially compostable) This is when composting occurs at a large-scale permitted facility which uses specific technologies to break down a variety of organic material Other packaging may be designed to be home compostable (also known as backyard compostable) This is when composting takes place in small piles or containers at a residentrsquos home

Commercial composting in the United States began in earnest in the late 1980s and early 1990s when the country perceived a ldquolandfill crisisrdquo - landfills running out of space and full of garbage In response municipalities started passing ordinances banning yard waste from landfills Prior to that little composting was being done on a large scale(Waste360)

In the 2010s the push for ldquogreen infrastructurerdquo development in urban areas (including stormwater management efforts and LEED certification) and the growing trend of regenerative agriculture created significant demand for compost products At the same time community composting which is typically a small-scale composting program managed by a local community took off in part due to ldquodemand for better soils for community gardens and urban farmsrdquo (BioCycle 2020)

Today the composting industry has grown significantly but continues to operate on a fairly decentralized level with collection programs and composting operations varying widely from state to state A renewed overall emphasis on soil health is boosting compost markets and landfill disposal bans or mandates continue to be effective tools for driving organic material to composting (BioCycle 2020)

The global compost market is expected to reach an estimated $92 billion by 2024 with a compound annual growth rate (CAGR) of 68 from 2019 to 2024 (Compost Market Report) This is slightly higher than the projected growth rate of the plastic recycling industry (54) and double the projected growth rate of the paper recycling industry (34) 9

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 15: Understanding the Role of Compostable Packaging in North

The goal for compostable packaging should be for it to get composted The composting process provides important climate change benefits with soils serving as a critical carbon sink However as composting infrastructure is still being developed it is likely that compostable packaging may initially be landfilled

There is significant confusion around what happens to compostable packaging in a landfill and whether its property of biodegradability is still beneficial Conditions at a composting operation are very different than conditions at a landfill and landfills have different families of microbes that behave differently than those at composting operations Some compostable bioplastics will not biodegrade in landfill conditions others will Similarly compostable packaging may or may not biodegrade in terrestrial or marine environments

Landfills are engineered to prevent any interaction of landfill waste with the surrounding environment so there will be no completion of naturally-occurring biological cycles when something biodegrades in a landfill Landfills are the third-largest source of man-made methane emissions because material breaks down in the absence of oxygen which generates much more methane than biodegradation at composting facilities From a carbon footprint perspective itrsquos best if nothing biodegrades in a landfill

Regardless of whether compostable packaging is composted it may still have important environmental benefits This is because most of the impacts from packaging tend to come from the manufacturing and sourcing phases of the life cycle while the end-of-life impacts are less significant Compostable packaging tends to have lower greenhouse gas emissions and fossil fuel use during the sourcing and manufacturing life cycle phases than traditional packaging

Compostable Packaging in Landfills

10

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 16: Understanding the Role of Compostable Packaging in North

Collection

Collection Insights Into Composting Infrastructure amp Access

The predominant narrative regarding composting infrastructure and programs in the United States and Canada is that it is largely absent insubstantial and incapable of handling packaging This is a concern that is often cited by consumers who may feel misled or confused by compostable packagingrsquos disclaimer that ldquoComposting facilities may not be available in your areardquo

This narrative does not fully stand up to research that examines the current state of composting infrastructure in North America While access to composting programs is not universal free or widespread according to our research at least 27 of the US population has access to some kind of composting program that accepts either food waste only or food waste and some forms of compostable packaging More specifically at least 11 of the US population has access to composting programs that accept some form of compostable packaging in addition to food waste These programs differ widely and may include privately-run or municipally-run curbside service privately-run or municipally-run drop-off or programs or a combination of these

11

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 17: Understanding the Role of Compostable Packaging in North

To better understand the challenges and opportunities for composting GreenBlue has developed several interactive maps and charts of composting infrastructure and supportive legislation available on Tableau Public This data was collected from state databases of permitted waste facilities and individual facility websites Information about privately-run composting programs was supported by CompostNOWrsquos directory

In the United States 15 of composting facilities accept some compostable packaging

While 55 of the verified facilities accept only green waste (yard waste and other agricultural waste) facilities that accept food waste and some combination of other compostable materials are not insignificant mdash about 45 of the facilities identified accept these feedstocks Specifically about 29 accept food waste and about 15 accept packaging in addition to food waste

We see that 102 facilities take compostable packaging including compostable bioplastics from residential and commercial sources Another 28 take fiber-based compostable packaging (no bioplastics) and another 13 take compostable packaging from residential sources only In total 143 composting locations are accepting some kind of compostable packaging

Availability of Composting Infrastructure

Green Waste

Food Waste amp Compostable Packaging

Food Waste

535307

Figure 3 Breakdown of US composting facilities by material accepted

158

12

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 18: Understanding the Role of Compostable Packaging in North

In Canada 33 facilities accept uncoated fiber products such as paper plates food soiled paper and greasy pizza boxes and 10 facilities accept fiber packaging such as paper takeout containers Seventeen composting facilities accept food waste in addition to green waste but do not accept uncoated or coated fiber packaging or bioplastics An additional 36 facilities accept green waste only (ie no food waste fiber packaging or compostable bioplastics are accepted) One facility accepts compostable bioplastics Of the 97 total composting facilities identified in Canada around 44 accept uncoated fiber or fiber packaging

These data are constantly evolving as composting facilities open and close their locations accept new material or restrict incoming material and enter into contracts with local municipalities and waste haulers

This means there is enormous potential for growth in the composting industry - the number of facilities or the material they accept is not set in stone Rather industry can expand to divert more organic material from landfills closing biological loops and reducing greenhouse gas emissions

In Canada composting facilities often accept uncoated fiber products but bioplastics are not widely accepted

Figure 4 Breakdown of Canadian composting facilities by material accepted

375Green waste only

Food Waste 177

333Uncoated fiber only

All compostable products (includes bioplastics)

10

Fiber compostable products only

104

13

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 19: Understanding the Role of Compostable Packaging in North

Looking at composting facilities gives us important insights into the availability of infrastructure but there is an additional question to consider- how many people do these facilities serve To answer this question we explored residential access to composting programs Consumers can have access to composting programs through

Municipally-run curbside programs

Municipal-run programs are administered by the residentrsquos city or county and are generally considered to be easy to participate in with a lower barrier to entry This is because the resident typically already accesses other waste services through the municipality and composting is included in city communications For example the city of Austin Texas includes information about organics recycling alongside its other resource recovery programs

Privately-run curbside programs

Composting programs that are run by a private composting company such as CompostNow typically pick up material from residents and may take them to a nearby composter or process the material at their own composting site These programs are often structured as a monthly subscription service rather than on a weight or volume-based fee They are often built through word-of-mouth engagement and are used by motivated residents In some programs residents may receive finished compost

Drop-off programs

These programs can be municipally-run or privately-run and often offer multiple locations where residents can bring their food scraps and other accepted compostable items for composting Drop-off locations are typically free to use but in some cases may include a fee

Backyard composting is not considered in this analysis

Residential Access to Composting Programs

14

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 20: Understanding the Role of Compostable Packaging in North

Composting Programs in the United States

To get a better understanding of residential access to composting programs in the urban United States GreenBlue conducted an analysis of the 1000 largest cities in the US These cities represent 40 of the total US population

These cities were categorized by whether they have residential composting programs either through curbside collection or drop-off Composting programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

15

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 21: Understanding the Role of Compostable Packaging in North

16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

19 of the largest cities have some kind of composting program that accepts some form of compostable packaging

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

16

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 22: Understanding the Role of Compostable Packaging in North

Many densely populated counties in the US have insufficient composting infrastructure

Even though composting may be more widespread than many believe itrsquos still largely insufficient When we look at dense counties and their access to composting facilities itrsquos clear that many of the USrsquos most populous areas (cities with populations of more than 36000 people) do not currently have sufficient access to composting food waste or packaging For example Southern Californiarsquos high population areas like Los Angeles and San Diego have a handful of facilities in their respective counties but these likely lack the scale and capacity needed to accept the large volumes generated New York City has delayed the roll-out of its municipal composting programs and the densely-populated surrounding Tri-State area also lacks sufficient composting capacity

While this research examined the largest urban areas in the United States rural and suburban areas may also have access to curbside composting programs particularly if state or municipal governments require food waste to be diverted from landfills - see Legislation that Supports Infrastructure

For a full outline of the data refer to the Appendix Information on access to curbside composting programs is continually in flux since it depends on the operations of local composting facilities and the details of municipal programs Additional research on access to residential composting programs has been conducted by BioCycle

17

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 23: Understanding the Role of Compostable Packaging in North

Composting Programs in Canada

What kind of residential access to composting exists in Canada While GreenBlue did not conduct a separate analysis of urban access to composting programs in Canada we can gain insight from existing data According to data from 2011 63 of Canadian households that had composted their green waste and 60 that composted their kitchen waste used a curbside collection system while the rest used a compost bin or pile or some other method to compost (StatCan) In British Columbia 64 of the population lives in regions with organic waste bans and organic diversion programs in place (BC) Montreal plans to provide composting services to citizens across the province as well as to all industries businesses and institutions by 2025 (Montreal) On the whole Canada has more widely-established food waste composting programs than the United States In the table below we can see a sampling of the some of the largest cities and the curbside programs that accept at a minimum food waste

City Municipal Waste Program PopulationToronto ON Green Bin Program 293000 (2017)

Montreal QB Food Waste Program 178000 (2017)

Calgary AB Green cart food and yard waste 133600 (2017)

Ottawa ON Green Bin Program 994837 (2017)

Edmonton AB Pending Rollout - Organics Program 981280 (2017)

Vancouver BC Food Scraps Recycling Program 675218 (2017)

Hamilton ON Green Cart Program 549200 (2017)

Surrey BC Organics Cart 518467 (2017)

Halifax NA Green Cart Program 431479 (2017)

Saskatoon SK Green Cart Program 273010 (2017)

Regina SK Food and Yard Waste Pilot 228928 (2017)

Charlottetown PE Compost Cart 36094 (2016)18

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 24: Understanding the Role of Compostable Packaging in North

In the study of the top 1000 cities in the US by population we also looked at how many of these cities are in states with ordinances requiring businesses and in some cases residents to compost their food waste This gives us insight into how many cities will begin to offer food waste composting in the near future in order to comply with these ordinances

States with ordinances include California New Jersey New York Massachusetts Connecticut Vermont and Rhode Island Of the largest 1000 cities in the US 309 cities are in states with food waste ordinances These cities represent 13 of the total US population This is important for future developments to composting infrastructure since cities in these states are likely to face limited composting infrastructure and will need to have conversations about how to increase their capacity and access to programs if they are to be in compliance with their statersquos mandates Enforcement which is often lacking will be necessary to make sure these ordinances are effective

In addition to these states a handful of cities and counties have also passed food waste legislation which requires generators to compost food waste and other organic materials when feasible This

legislation is mostly limited to Northeastern or coastal cities with the exception of Minneapolis Austin and Boulder However food waste legislation doesnrsquot have to be a coastal phenomenon Additional cities and states across the country may be well-suited for this type of legislation because of their access to composting infrastructure For example Chicago is in close proximity to a number of composting facilities that accept food waste and in some cases packaging

Legislation Banning Food Waste from Landfills

Legislation that Supports Infrastructure

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

19

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 25: Understanding the Role of Compostable Packaging in North

A look at the data above reveals the nuances of composting infrastructure and collection programs in the United States and Canada We can see that not only does composting exist in greater numbers than expected but a notable amount of facilities and programs accept food waste and compostable packaging

In short there are several key takeaways from the data

ų 15 of US composting facilities accept some kind of compostable packaging

ų A third of the largest US cities have curbside composting programs that accept food waste and around 20 also accept compostable packaging

ų The majority of Canadarsquos large cities offer food waste curbside collection programs

ų Food waste legislation is an important lever for driving new composting infrastructure and collection programs

Key Takeaways for Composting Collection

How likely is it that a compostable package will be collected for composting Understanding residential access to composting programs is an important first step in beginning to answer this question but the full story is yet to be written The answer will depend on how many of these programs are opt-in versus opt-out have high participation rates and are accessible to both single-family and multi-family households

20

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 26: Understanding the Role of Compostable Packaging in North

Composters are an essential part of the compostable packaging ecosystem - without them compostable packaging will not get composted Itrsquos critical to understand how composters manage their technologies operations and end-markets

Composting

Composters Understanding Technologies amp End Markets

21

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 27: Understanding the Role of Compostable Packaging in North

The most common types of commercial composting technologies are

In-vessel composting in which organic waste is fed into a drum silo concrete-lined trench or similar equipment (EPA)

These technologies may be supplemented with covers that build heat and retain moisture Compostersrsquo preference towards one of these systems may depend on a number of factors including climate feedstocks processed permits and the age of their facility

Facilities may also choose to limit the types of material they accept As previously mentioned some facilities only accept green waste (also known as yard waste) Small-scale composting operations may choose not to accept dairy or meat because of challenges with odor or vermin Commercial composting facilities are typically able to handle a variety of biomass including all types of food scraps yard waste and plant trimmings fiber-based materials such as paper towels hair and fur and cardboard

Windrow composting in which organic waste is formed into rows of long piles and periodically turned either manually or mechanically

Aerated static pile (ASP) composting in which organic waste is mixed in a large pile and designed so that air can pass from the bottom to the top of the pile Piles are often aerated with a network of pipes or with air blowers that are activated by a timer or sensor

Types of Composting Technologies

22

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 28: Understanding the Role of Compostable Packaging in North

Composting facilities are ultimately product manufacturers making finished compost that is applied to range land agricultural land landscaping green roof installation new construction and road sides There are many uses for compost and the buyers for finished compost are varied They include farming operations state agencies construction firms landscapers and consumers As one example LEED has recognized compostrsquos benefits and has created specifications for its application on LEED-certified buildings The end markets for finished compost vary greatly by state and geographic region

For most of these applications finished compost must be nearly entirely free of visual impurities another reason why managing contamination is critical For example in Washington state the Department of Transportation specifies that the compost it purchases must have less than 05 percent ldquomanufactured inert material (plastic concrete ceramics metal etc)rdquo In other states or for other applications the tolerance for visual impurities may be higher and customers tend to set the standard for what kind of finished product composters can sell

The end-markets for finished compost vary greatly In some regions finished compost is used in municipal projects such as road-side application while in other regions

finished compost goes into the agriculture industry In regions without these end-markets it may be harder to find buyers for finished compost If the finished product has substantial visible impurities it may be more difficult to sell or may need to be sold at a lower price All of these factors depend on the region where the compost is being manufactured and sold

There are a number of certifications available for finished compost One is the US Composting Councilrsquos Seal of Testing Assurance Program or STA Compost manufacturers participating in the STA Certified Compost program are held to high standards for using quality labs testing frequently disclosing specific information about their product and following regulations Finished compost may also be certified organic by the Organic Material Review Institute (OMRI) OMRI certification based on National Organic Program standards currently restricts the use of bioplastics and other manufactured inputs as a feedstock in the production of compost although this is being reevaluated by the industry

End Markets for Finished Compost

23

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

Page 29: Understanding the Role of Compostable Packaging in North

The success of the composting industry depends on the strength of the end-markets for finished compost In the same way that brands need to consider whether recyclers are able to find end markets for recyclable packaging the compostable packaging industry should consider how packaging fits into compostersrsquo profitability and finished product

Since manufacturers and brands donrsquot typically purchase finished compost directly the composting system doesnrsquot have the same pull-through as recycled content for packaging Rather the system depends on a different industry such as agricultural or construction for the pull-through It is important that brands understand these end market dynamics Though brands may not drive demand for finished compost directly they should support broad education and engagement around the benefits of composting

Be part of the solution Companies can support the composting industry by purchasing finished compost when possible and advocating for the application of finished compost as part of agriculture transportation and construction projects They can also join the USCC Corporate Compost Leadership Council and engage in policy - a number of states have passed legislation that supports end market development for compost

Does the technology used at a composting facility impact its ability to process packaging

Yes but itrsquos usually not the determining factor All of the technologies listed above can be used to process compostable packaging Windrow composting may give more time for materials to break down than ASP composting while ASP may break down materials more easily due to more tightly-controlled air and moisture However these are not hard and fast rules

Typically a facilityrsquos ability to process compostable packaging will depend on its willingness to work with the material and the amount of time that materials are given to break down in the active composting phase A facility that operates under shorter time frames such as 30 days may find that the packaging has not broken down Ultimately how quickly and readily packaging biodegrades into compost depends on variables such as operating procedures temperature moisture and climate

24

Contamination is an ongoing issue for composting facilities It can take many forms and packaging is just one possible source - household goods such as garden hoses in yard waste and conventional plastic items are common contaminants When it comes to packaging what is considered contamination will vary by facility but may include

ų Packaging that is not designed to be compostable such as conventional plastic bags produce stickers and glass bottles

ų Packaging that is certified compostable but is not accepted by the facility (eg because the facility only accepts food waste or food soiled paper)

Higher levels of contamination are closely linked to increased recovery of food waste as residents and commercial businesses businesses incorrectly sort non-compostable packaging and other items and include contaminants with their food scraps (Cascadia Consulting 2020) This is why facilities may avoid accepting food scraps and choose to only process green waste

Does compostable packaging contaminate a composting facility

Though facilities that do not accept compostable packaging may consider it a contaminant it is usually not the biggest culprit Typically the majority of contamination at composting facilities is from non-compostable materials particularly non-compostable plastics In one study of composting infrastructure in Washington State contamination of incoming material was 39 by weight This contamination included ldquononcompostable plastic glass and noncompostable papers such as aseptic and polycoated papersrdquo (BioCycle 2019)

Many facilities struggle with contamination from ldquolook-alikerdquo food serviceware items that are not compostable but appear identical to compostable packaging In these instances composters must decide whether to allow the packaging to move through their process assuming it is compostable or remove it as a contaminant assuming it is not compostable Though look-alike items are most commonly an issue for plastic packaging it can also be an issue for fiber-based packaging

Addressing Contamination

25

Removing and disposing of contamination is an extremely important added cost for composting facilities At some facilities contamination-removal is done at the beginning of the composting process using equipment such as Trommel screens More often it is done at the end of the composting process when the finished product is screened and any large pieces of material (ldquooversrdquo) are removed At some composting facilities the ldquooversrdquo are sent through the composting process a second time or they may be landfilled

Do standards for compostability match composting facility conditions

One common concern about compostable packaging is that it will not break down in a facilityrsquos operating time frame or conditions frequently referred to as ldquoreal-worldrdquo conditions To better understand this concern it helps to review how compostability standards are set

To determine if packaging is compostable certification programs typically use independently-developed third-party standards In North America ASTM is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials products and services The standards for packaging that is designed to be industrially composted are ASTM D6400 for compostable bioplastic packaging and ASTM D6868 for fiber packaging with compostable bioplastic coatings or additives The ASTM standards were first developed in 1999 based on science-based test methods (learn more here)

Today there is an increasing desire to have the ASTM standards reverified by data from the field This work is being done by the Compost Council Research and Education Foundation and the Compost Manufacturing Alliance and is supported by the North American certifier the Biodegradable Products Institute (BPI)

26

Not made of 100 compostable materials Certified compostable materials

Without prominent labeling it can be impossible for composters to distinguish between a compostable bioplastic and a conventional plastic or between a bioplastic-lined container and a polycoated container

Because composters use machinery to handle loads of compostable material product labeling should be visible from a distance using prominent striping or color-coding

Contamination from Look-Alike Packaging

27

Be part of the solution Brands should certify all compostable packaging to ensure that it fully decomposes and does not leave toxic residue Field testing by groups like the Compost Manufacturing Alliance can be used to verify that packaging is breaking down in a variety of timeframes and conditions Review BPIrsquos labeling guidelines to ensure that your compostable packaging is properly labeled to help reduce contamination

Companies can also consider supporting legislation that outlines which kinds of materials should be used for food serviceware and food contact packaging For example it may outline that all food serviceware or cutlery must be certified compostable or may require that only certified compostable bags be tinted green This kind of legislation helps limit the issue of look-alike packaging by requiring compostability in certain applications and helps reduce consumer confusion when disposing of packaging - see The Future of Compostable Packaging

ldquoIt is not operationalhellip These products break down That is not the issue The clear labeling is for the consumer [to sort properly] because once the products are in the bin it is hard to distinguish them from conventional plastic packaging Thatrsquos why we tend to prefer fiber-based certified compostable packagingrdquo

Tim Dewey-Mattia Napa Waste amp Recycling Services BioCycle

28

Consumers play an important role in pushing for compostable packaging and being the ones to actually put packaging into the compost bin While many are motivated to seek out compostable packaging consumers need better ways to distinguish it from conventional plastic packaging

Consumer Engagement

Consumer Engagement Communicating Compostability to Consumers

29

Increasingly consumers report a preference for packaging to be compostable At the same time there is widespread confusion about compostable packaging - some consumers believe that it helps prevent ocean plastic pollution breaks down in landfills is always preferable to recyclable packaging or is synonymous with biodegradable packaging These assumptions are not true but may nevertheless be driving consumer demand

Three recent studies help illuminate how compostable packaging is perceived by consumers

A survey of European consumers found that 32 of consumers believe this type of packaging is the least damaging for the environment and 50 of consumers would buy a product for its compostable packaging (Amcor)

In the UK 85 percent of surveyed consumers believe that food packaging should be compostable with two thirds of those asked agreeing that the food industry should lead the move towards compostable packaging (resourceco)

In the US 60 of surveyed consumers called compostable packaging ldquoextremely or very eco-friendlyrdquo (EcoFocus) and 71 of Millenials feel positive towards companies that only use packaging that is compostable (Evergreen Packaging)

Consumer Perceptions of Compostability

30

Despite considering compostable packaging as preferred and eco-friendly consumers still have a hard time understanding the nuances In the same survey of European consumers upwards of 50 of respondents could not identify the corresponding logo and consider biodegradable and compostable as interchangeable (Amcor) There is also ongoing consumer confusion about which packaging is recyclable and which is compostable particularly when it comes to transparent compostable bioplastics This is particularly problematic because consumers are the first line of defense in properly sorting materials and preventing contamination since it isnrsquot always possible to identify a compostable item once itrsquos mixed in with other materials

More needs to be done by brands to make it clear which packaging is compostable what should be done with it and how ldquocompostablerdquo is different from ldquobiodegradablerdquo All compostable packaging should be certified compostable by a third-party organization that verifies product attributes and claims A certification body issues a product the ldquocompostablerdquo logo after reviewing independent lab results that test for compostability

In North America the predominant certifier of compostable packaging is the Biodegradable Products Institute (BPI) It is based on the third-party standards ASTM D6400 and ASTM D6868 and certifies packaging for industrial composting environments

Itrsquos important to note that there is no North American certification for home compostability and no corresponding ASTM standard There are two European certifications that may be used for products that are sold in both European and North American markets The TUV Austria OK Compost certification is based on the EN 13432 standard There is also the European Bioplastic ldquoSeedlingrdquo mark which is based on the EN 13432 and EN 14995 standards

Education Through Certifications amp Labeling

31

Certification programs like BPI go beyond certifying that a package breaks down in a given timeframe BPI has strict eligibility criteria that are unique to its program 1) the item must be associated with desirable organic wastes like food scraps and yard trimmings that are collected for composting 2) the item cannot be a redesign of an item that is a better fit for recycling based on existing demand infrastructure and consumer awareness (eg water bottles) and 3) the item cannot require disassembly in order to be composted Products may not have intentionally added per- and polyfluoroalkyl substances (PFAS) and the presence of these chemicals must be limited to 100 PPM

Once certified products should prominently bear the certification mark on the product BPI requires that all certified items and associated packaging must be labeled with the BPI Certification Mark unless a category level exemption is in place This requirement is in place as a best practice to combat contamination from non-compostable products

In addition to logos brands should use prominent labels stripes and green or brown coloring to distinguish compostable packaging These colors have been identified as industry guidelines and are stipulated in state labeling legislation Finally brands should consider including additional information that distinguishes between home and commercially compostable and that helps consumers identify their local commercial composting facilities

At the same time brands should avoid recyclability symbols or language on packaging that is designed to be compostable Compostable packaging should not be labeled with similar words such as ldquobiodegradablerdquo ldquodegradablerdquo ldquodecomposablerdquo or ldquooxo-degradablerdquo

32

One way to help consumers understand compostability is to use the How2Compost label How2Compost is a standardized on-package label that clearly communicates composting instructions to the public and all BPI-certified items are eligible

A few unique call-outs in the How2Compost label help consumers compost correctly Here we see a label that a PLA cold cup might receive with a special call-out at the top that the item is ldquoNot Yet Recyclablerdquo While PLA is technically recyclable per Federal Trade Commission guidelines consumers do not have access to recycling collection for PLA nor is there an established end market or established sortation nationwide which means that it cannot be claimed as recycled per Federal Trade Commission guidelines For the time being a compostable bioplastic like PLA can only be composted Appropriate labeling helps minimize consumers unintentionally contaminating the recycling stream with PLA and increases the successful disposal of compostable items either to a compost bin if available or to a trash bin if no composting bin is accessible

The How2Compost label is designed to be used in tandem with the How2Recycle label when relevant This means that for compostable packaging or food serviceware that comes in packs and uses a recyclable paperboard box or PE sleeve for instance both the How2Compost and How2Recycle labels can be used to explain how a consumer should recover every piece of the packaging system

For more on labeling refer to BPIrsquos guide for labeling compostable packaging to make it easily identifiable for both consumers and composters

Be part of the solution Brands play a critical role in educating consumers through consistent and clear messaging By following the guidelines and resources above brands ensure that all stakeholders are able to easily identify compostable packaging and prevent compostable packaging from contaminating the recycling stream

33

Brands may be hesitant to draw attention to the limited composting infrastructure Yet this is key to building trust and transparency with customers and other stakeholders and can also help ensure that compostable packaging gets composted in the municipalities where composting is available When brands draw attention to the limited infrastructure they also encourage consumers to learn what is available to them

For instance consumers may not be aware of privately-run rather than municipally-run composting services in their area or the option to take material to a drop-off site Brands can share resources that help consumers identify composting facilities such as GreenBluersquos composting maps and the FindAComposter site

Even when compostable packaging is not widely accepted at facilities brands can begin to activate composting behavior in consumers by encouraging them to compost their food waste As just one example Novamont a bioplastics manufacturer created an app to teach kids how to recycle food scraps

Brands and manufacturers can also create educational campaigns to help clarify the distinction between ldquocompostablerdquo and ldquobiodegradablerdquo and the properties of compostability as in this Pepsi video

It is important to clearly communicate to consumers that compostable packaging does not outperform other materials in a landfill and that it does not ldquocompostrdquo in a landfill Brands can explain that they may be choosing compostable packaging due to lower environmental impacts during sourcing or manufacturing rather than end-of-life benefits

Be part of the solution Brands may also want to encourage customers to reach out to their local municipality to express interest in composting programs They may consider providing template letters for community outreach or petitions that make it easy to express interest Consumers that are not able to compost locally but would like to are powerful allies in advocating for new composting programs and facilities

Engaging Consumers on Composting

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation

34

Design

Design Starting with the Right Applications

The first step to designing compostable packaging is to understand whether it is the right fit for your packaging application Compostable packaging should not be a blanket solution for all packaging

Rather compostable packaging should be used in applications where it helps divert food waste out of landfills and into compost bins reduce food scrap contamination of recyclable materials or replace non-recyclable packaging

This will help brands prevent problems down the road Issues with certification and composter acceptance are likely if compostable packaging is used to replace packaging that doesnrsquot come into contact with food

35

Here are the categories of packaging that can be effectively designed to be compostable

1 Packaging for prepared food in grocery stores and foodservice

Foodservice packaging for restaurants cafeterias venues and grocery store prepared food bars is the most natural fit for compostable packaging It includes packaging like takeout containers salad bowls taco trays soup bowls and the associated napkins cutlery sauce cups and lids Thatrsquos because this type of packaging is covered in food residue and leftovers and goes hand-in-hand with food consumption While large amounts of food contaminate recycling streams food scraps are exactly what composters are looking for

Designing this category of packaging to be compostable helps guide food scraps towards the composting bin rather than the recycling bin or the landfill It eliminates the need for consumers to sort food-contact items into different bins which they are apt to do incorrectly

Best Applications for Compostable Packaging

36

2 Food-contact packaging that is not readily recyclable

Today many food items are in packaging that is not readilyrecyclable Think of cuts of meat frozen food and cheese -these are just three examples of entire categories of productsthat are mostly in non-recyclable films lined paper trays orfoam packaging Usually they are not readily recyclable incurbside or store drop-off programs because of the designchoices made around the material and format and becausethe packaging is often covered in food residue

While today this is a less common application forcompostable packaging it can be a new frontier forforward-thinking brands As an example consider ketchuppackets Typically made of plastic film these wrappershave limited recovery options except as part of futureinnovations in advancedchemical recycling Meanwhilethere are bioplastics on the market that could replacethis film with a compostable option Any leftover ketchupwould be easy for the consumer to compost instead of landfillThis new compostable food-contact packaging would needto be certified for compostability and labeled for consumersHowever if approached correctly compostability may bethe right choice for many types of food-contact food-soiledpackaging that is not recyclable today

37

3 Fiber packaging that becomes food soiled

Some fiber packaging that becomes food soiled may be better suited towards composting than recycling Consider fiber-based e-commerce packaging used as dividers or holders in meal kitsor grocery delivery If it becomes heavily food soiled from theproducts inside it may no longer be recyclable This materialis often uncoated corrugated cardboard which is readilycompostable but consumers will need to first understandwhether they should recycle or compost this packaging In thesesituations companies should consider labeling the packaging ina way that communicates a hierarchy of decisions For examplethe How2Recycle and How2Compost labels can help educateconsumers to recycle the item if itrsquos clean and dry or compost itif itrsquos food-soiled

4 Packaging that is a contaminant at composting facilities

Composting facilities that accept food waste already have to manage unwanted contaminants from non-compostable packaging These items are food-related and ldquoride alongrdquo with the food scraps that consumers and businesses are trying to compost This can include items like sauce cups produce stickers meat trays plastic wrap around produce salad bags rubber bands and twist ties Making these items compostable would provide high value to composters because it would help to solve a contamination problem while helping to bring in food

For these categories of packaging compostability is a promising recovery option38

Checklist for Compostability

ų Is your packaging used to serve prepared food Compostable packaging makes it easy for consumers to compost any leftovers of prepared food

ų Does your non-recyclable packaging contain frozen or raw food Compostable packaging can replace meat produce and frozen food packaging that is not recyclable Any food residue from these contents can be composted alongside the packaging

ų Will your packaging bring in food to the composting facility Food residue may make your package too dirty to be recycled Instead significant remnants of uneaten food may be a sign that the packaging is a better fit for compostability

ų Is your packaging a common contaminant at composting facilities Designing for compostability for packaging items like sauce packets and salad bags helps to address compostersrsquo challenges with contamination These items are already coming into composting facilities along with food and designing them to be compostable would help composters

ų Do consumers typically throw away food waste along with your packaging Consumers do not always separate food waste from its packaging and may be throwing non-compostable packaging into the compost bin For packaging that is difficult to cleanrinse such as salad bags compostable packaging can instead allow consumers to easily compost both the bag and the spoiled contents

ų Does your fiber packaging get food soiled Fiber packaging that becomes food soiled may not be suitable for recycling Compostability may be a better choice for food-contact fiber packaging

39

packaging Brands and retailers should think holistically about the entire product-package system including secondary packaging so that compostable packaging does not contaminate the recycling stream and recyclable packaging does not contaminate the composting stream

With some food packaging such as for baked goods or cheese products there will typically be very little food residue under normal use by consumers However itrsquos worth considering the likelihood that the entire product will spoil during distribution or will not be sold to consumers If that were to happen compostable packaging may make it easier for retailers to compost these items

There is no clear formula for what kinds of packaging should be compostable Rather it depends on a variety of variables many of which have been outlined above In many applications such as food serviceware salad bags and produce stickers the case is clear Compostability in these instances helps to bring more food waste to composters and addresses common contamination challenges

Yet a number of gray areas exist where it is unclear whether packaging should be compostable For example there is no established definition for how much food is required for something to be considered ldquofood soiledrdquo In general the more food that can be diverted to a composting facility the more value the packaging brings to a composter but there is no exact threshold An item like a candy wrapper may not always be food soiled and may bring very little food scraps to a composting facility At the same time candy wrappers may already be a common contaminant at composting facilities and making them compostable might help alleviate this problem for composters

There is also limited data on exactly how much food residue presents a contamination challenge at recycling facilities Plastic reclaimers have washing procedures in place to remove food residue but too much food residue may be a sign that the product is better suited for compostable

Gray Areas for Compostable Packaging

40

Brands and retailers need to think carefully about the entire life cycle of their packaging and its context asking questions like

ų Is this item used primarily on-the-go in closed venues such as stadiums or at home What is the likelihood that it will be collected for composting in this setting

ų Is this item sold as part of a suite of other materials that are also compostable Is this item sold as part of a suite of other materials that are predominantly recyclable

ų In the case of secondary packaging is it going around an item that is compostable such as tea bags or compostable coffee pods

ų How much food remains in or on the packaging after it is used by consumers Is the food residue dry wet moist sticky gooey or oily

ų How is it currently being disposed of Is it a common contaminant at recycling facilities At composting facilities

Ultimately brands and retailers should lean into these unknowns and have conversations with municipalities composters and customers to better understand how their packaging may or may not fit into the composting stream

Another example is compostable cups for hot or cold drinks Recyclable cup designs are available however in a closed loop venue it may make more sense to serve compostable cups in conjunction with other compostable food serviceware to create a suite of compostable packaging Given the closed nature of the venue and the other products being used it is often more effective to simplify the messaging to consumers by telling them to put everything in one bin Using recyclable cups in this instance may contribute to confusion or contamination

There is little guidance on whether compostability is appropriate for packaging that contains non-food products such as personal care products These products may need to be certified separately to ensure they do not pose toxicity or disintegration problems in a compost facility and no certification is currently addressing this

41

Todayrsquos composting systems are still ramping up which means many municipal programs and composting facilities are just starting to accept food waste In many cases they do not yet accept food-soiled compostable fibers and are not currently comfortable accepting compostable bioplastics While the composting industry learns to manage these feedstocks it should not be overburdened with packaging especially packaging that is not related to food

A variety of packaging categories should not pursue compostability These include

ų Rigid readily-recyclable plastics such as PET water bottles Most conventionally-designed rigid plastics can be mechanically recycled and making these products compostable may cause consumer confusion

ų Personal care and cosmetics packaging including sachet formats Leftover product inside the packaging may not always be safe as a feedstock for compost and these feedstocks would not typically be well-received by composters

ų Packaging thatrsquos not used for food If the packaging is not used for food it will not achieve the goal of sending more food waste to composters

In these cases brands may choose to design packaging using bio-based materials and these bio-based materials may also be theoretically compostable at their end-of-life However rather than marketing the compostability to their customer brands can instead emphasize the environmental benefits of sourcing bio-based materials and not encourage consumers to compost these products

What Shouldnrsquot Be Compostable

42

Cosmetics

Pet FoodConfectionery Seafood Fish Dressings Sauces

Cleaning Products Clothing

Bulk

Vegetables

Tea Coffee Outer Packaging

Cannabis amp CBD

Breads Bakery

Food CourtFruits

Alcoholic Beverages

E-commerce

Furniture amp Household Goods

Meat Department Dairy Products Eggs

Packaging with food scraps (eg food serviceware)Packaging with wet food residue (eg salad bags)

Food-contact packaging with moist sticky gooey or oily residueFood-contact packaging with dry food residueFood-contact packaging with no food residue

Packaging that is not in contact with foodPersonal carecosmeticscleaning products

Best fit

May be a fit

Not a good fit

A Note About Chemicals of Concern

Regardless of the context all compostable packaging needs to be free of chemicals of concern Much attention has been given to per- and polyfluoroalkyl substances (PFAS) which are used to impart grease and water resistance to certain categories of compostable packaging These chemicals are no longer permitted in BPI-certified compostable packaging as of January 2020 Substitutions to these chemicals need to be carefully considered and all additives used in compostable packaging need to be screened for potential health concerns This is why BPIrsquos certification screens for carcinogens reproductive toxins and mutagens

43

The success of compostable packaging requires a renewed focus on recirculating biological nutrients like food scraps fibers and plant material Today many of these nutrients are landfilled or mixed in with technical nutrients and are not returned back into the biosphere This is a lost opportunity to manage our resources in a way that does not produce methane or carbon dioxide while also building the health of biological systems

What might compostable packaging look like in the next decade And more importantly what will the ecosystem of collection access and consumer engagement surrounding compostable packaging be Herersquos a glimpse into what our future can look like if we actively address todayrsquos challenges

The Future of Compostable Packaging

44

In the future wersquoll sustain biological loops Wersquoll understand the importance of healthy soils for sequestering carbon and feeding growing populations To restore soils wersquoll use compost to increase crop yields and better absorb rainwater The compost we require will be created with the food waste wersquore currently landfilling This food waste will be collected more easily with compostable packaging and kept away from technical nutrients like aluminum and plastic Municipalities will offer collection programs for a wide variety of biological nutrients and composting facilities will process this material for local and regional use including farming landscaping and the growth of crops for packaging applications

Biological amp Technical Cycles of the Circular Economy

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept

45

We can design compostable packaging to sustain biological loops by

ų Eliminating all chemicals of concern Compostable packaging will need to be free of chemicals of concern that may persist in biological loops A number of compostable packaging certifiers including the Biodegradable Products Institute (BPI) and Compost Manufacturing Alliance (CMA) already restrict the levels of fluorinated chemicals (PFAS) allowed in certified compostable packaging Packaging manufacturers using other certification programs such as TUV Austriarsquos OK Compost logo will need to eliminate PFAS and other chemicals of concern

ų Designing for faster biodegradation Todayrsquos compostable packaging is designed to break down in accordance with ASTM D6400 and D6868 standards Some compostable packaging breaks down much more quickly than what the standards require while other packaging may require the full timeframe stipulated in the standards While many composting facilities successfully process compostable packaging designed to these timeframes shorter degradation times would enable more facilities to integrate compostable packaging into their process

ų Designing smart compostable packaging that can detect and prevent spoilage Compostable packaging should be used in applications where there is a high likelihood of spoilage and food waste such as takeout food produce and meat At the same time we need to reduce the instances of food waste and spoilage which in some cases is as high as 40 of all edible food Compostable packaging can prevent spoilage by integrating sensing technologies such as those that respond to temperature changes that may affect whether a product is still safe to consume

Future Design

Eliminate chemicals of concern in packaging and explore RampD innovations that advance compostable materials

46

We can collect compostable packaging in a way that sustains biological loops with

ų Widespread curbside collection of food waste Food waste and food soiled paper is a significant part of the municipal solid waste stream As municipalities pursue zero waste goals and work to lower their environmental impact they will need to manage food waste in a new way For some municipalities curbside food waste collection can be added on existing green waste programs while others will need to create both programs at once Municipalities can also partner with existing private composting companies that service their area incentivizing residents to participate in these programs

ų Food waste legislation that makes composting programs more widespread Food waste legislation which requires generators to separate and compost food waste is a powerful driver of growth in the composting system Municipalities with a reasonable number of composting facilities can consider passing new food waste legislation This would give composters in these areas a welcome boost in demand for their services As facilities become comfortable accepting food waste and managing related contaminants they may begin accepting fiber compostable packaging or compostable bioplastics

ų Collection programs that outline when compostable packaging should be used Municipalities can play a role in improving the quality and economics of composting by outlining what types of packaging should be used by businesses For example municipalities can require all food service and food-contact packaging to be certified compostable This helps to eliminate look-alike non-compostable packaging at composting facilities Standardization among local ordinances will help manufacturers meet the needs of multiple markets while also reducing confusion among consumers

Future Collection

Engage with the Biodegradable Products Institute Plant Based Products Council and the US Composting Councilrsquos Target Organics group to advance local and federal legislation around composting

47

We can compost packaging in a way that sustains biological loops by

ų Building and retrofitting more composting facilities To process the millions of tons of food waste currently being landfilled we need substantial investments in new and expanded composting infrastructure This can come in the form of federal and state grants private investment investments firms focused on the circular economy and corporate funding Facilities can also be funded by compostable packaging manufacturers converters and brands who use compostable packaging For example in Italy compostable producers pay environmental contributions into the national packaging waste extended producer responsibility (EPR) program that funds composting collection programs

ų Turning to more advanced composting technologies Composting facilities can use pipes probes and other technologies to better monitor and regulate air flow temperature and moisture levels in composting piles In some cases renovating a composting facility from a windrow system to an aerated static pile (ASP) system that uses these technologies enables the facility to process more material more quickly This will be key to efficiently processing large volumes of municipal food waste At the same time it will be important to ensure that compostable packaging is given enough time to break down in these advanced systems

ų Using separate streams for non-organic feedstocks Some compostable packaging is not currently allowed as a feedstock for organic-certified finished compost Until standards for organic finished compost are amended composting facilities can develop separate processing flows for organic and non-organic compostable material This will allow facilities to accept more material than if they only accepted wastes that are suitable for organic-certified finished compost

Future Composting

Understand todayrsquos composting infrastructure and explore funding mechanisms for financing composting facilities

48

We can educate consumers about compostable packaging to sustain biological loops with

ų Clear prominent labeling on compostable packaging Brands using compostable packaging should use large prominent words and symbols to communicate compostability to consumers Compostable packaging should not be unlabeled mislabeled with words like ldquobiodegradablerdquo or use overly subtle markings such as embossing or printing on the bottom of an item Brands can use the How2Compost label to add instructions for how to distinguish between recycling and composting a package

ų Laws that require distinct labeling for compostable packaging Legislation such as Washington Statersquos HB 1569 outlines how compostable products must be labeled including certification logos colors stripes and other markings This kind of legislation may become more widespread as other state and national bills seek to differentiate compostable packaging from non-compostable alternatives

ų Consumer-facing resources for identifying access to composting programs Until composting access is widespread compostable packaging will continue to bear the disclaimer that commercial composting is only available in certain areas Brands and manufacturers can help consumers understand if composting is available in their municipality by creating and sharing resources such as look-up tools and apps that identify composting programs This will help to ensure that consumers with access to composting programs are aware

Future Consumer Education

Clearly label compostable packaging with colors stripes or the How2Compost label and incorporate consumer resources for composting into websites and social media channels

49

With a newfound understanding of the right approach to compostable packaging brands can use compostable packaging to meet their sustainability goals and sustain the biological loops of the circular economy

50

An analysis of municipally-run or privately-run composting programs looked at the 1000 largest cities in the US These cities represent 40 of the total US population Programs that only accept green waste and do not accept food waste were not included in this analysis

As of October 2020 the following insights can be drawn about urban access to composting in the United States

ų 16 of the largest cities have some kind of composting program that accepts food waste (not including packaging)

157 cities have access to some kind of composting program that accepts food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 16 of the total US population

ų 19 of the largest cities have some kind of composting program that accepts some form of compostable packaging in addition to food waste

193 cities have access to some kind of composting program that accepts some form of compostable packaging in addition to food waste whether that is a municipally-run or privately-run curbside collection program or a municipally or privately-run drop-off program These cities represent 11 of the total US population

ų 11 of the largest cities have curbside composting programs that accept food waste (not including packaging)

111 cities have either municipally-run or privately-run curbside composting programs that accept food waste These are typically opt-in programs - residents are not required to participate except in cities where composting food waste is required by law (see Legislation) These cities represent 12 of the total US population

Appendix

51

ų 19 of the largest cities have curbside composting programs that accept some form of compostable packaging in addition to food waste

19 accept some form of compostable packaging in addition to food waste through either municipally-run or privately-run curbside composting programs This may or may not include compostable bioplastics For example some programs may accept unlined fiber packaging such as paper plates and containers but not accept cold cups or utensils made from bioplastics In other instances programs may accept uncoated paper items but not accept lined paper takeout containers or cups These cities represent 11 of the total US population

ų 12 of the largest cities have private curbside programs that accept some form of compostable packaging in addition to food waste

124 cities have privately-run curbside composting programs that accept some kind of compostable packaging in addition to food waste Not all of these programs accept compostable bioplastics - some only accept fiber packaging or unlined paper products such as paper plates These cities represent 8 of the total US population

ų 7 of the largest cities have municipal curbside programs that accept some form of compostable packaging in addition to food waste

71 cities have municipally-run curbside composting programs that accept food waste and some form of compostable packaging These cities represent 3 of the US population

ų 1 of the largest cities have municipal drop-off programs that accept some form of compostable packaging in addition to food waste

13 cities have municipally-run drop-off programs that accept some kind of compostable packaging in addition to food waste These cities represent 1 of the US population

52

Accepting food waste (no packaging) Accepting food waste and compostable packaging

Cities with any kind of composting access (municipal private curbside andor drop-off)

157 16 of cities analyzed 193 19 of cities analyzed

Population of cities with any kind of composting access (municipal private curbside andor drop-off)

52399722 16 of US population 35416952 11 of US population

Cities with municipal residential compost programs

33 3 of cities analyzed 71 7 of cities analyzed

Population of cities with municipal residential compost programs

4570688 1 of US population 10441248 3 of US population

Cities with private residential compost program

81 8 of cities analyzed 124 12 of cities analyzed

Population of cities with private residential compost programs

36406174 11 of US population 26118439 8 of US population

Cities with either municipal or private programs

111 11 of cities analyzed 191 19 of cities analyzed

Population of cities with either municipal or private programs

40257956 12 of US population 35268870 11 of US population

Cities with municipal drop-off programs 36 4 of cities analyzed 13 1 of cities analyzed

Population of cities with municipal drop-off programs

15056848 5 of US population 2130108 1 of US population

Cities with private drop-off programs 23 2 of cities analyzed 3 03 of cities analyzed

Population of cities with private drop-off programs

13945093 4 of US population 2917870 1 of US population

53

Figure 1 Ellen MacArthur Foundation New Plastics Economy Vision statement httpswwwellenmacarthurfoundationorgour-workactivitiesnew-plastics-economy

Figure 2 Pew Charitable Trust SYTEMIQ 2020 Breaking the Plastic Wave report page 10 httpswwwpewtrustsorg-mediaassets202007breakingtheplasticwave_reportpdf

Figure 3 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 4 GreenBlue 2020 Composting Facilities in Canada httpspublictableaucomprofileolga2630vizhomeCompostingFacilitiesinCanadaCanadaDashboard

Figure 5 GreenBlue 2021 Mapping Urban Access to Composting Programs httpsgreenblueorgworkcompostingaccess

Figure 6 GreenBlue 2020 Mapping Composting Infrastructure and Supporting Legislation httpsgreenblueorgworkcompostingmaps

Figure 7 GreenBlue 2021 Adapted from Remondis The Cradle to Cradlereg Design Concept httpswwwremondis-sustainabilitycomeninspiringcradle-to-cradle

Image Credits

54

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